Pakistan: Proposes documentation and CbC reporting requirements
On June 5, 2017, Pakistan's Federal Board of Revenue has presented a notification (Notification SRO 421 (I) / 2017) regarding Documentation and country-by-country reporting requirements in respect of transfer pricing. The proposed requirements are
See MoreIndia: CBDT notifies new safe harbour regime for cross-border transactions
The Central Board of Direct Taxes (CBDT) on 7 June 2017, has issued a new, relaxed, safe harbour regime in order to reduce transfer pricing disputes. The move is aimed at providing certainty to taxpayers, aligning safe harbour margins with industry
See MoreTurkey signs CRS Multilateral Competent Authority Agreement
Turkey has signed Common Reporting Multilateral Competent Authority Agreement (CRS MCAA) for the implementation of automatic exchange of financial account information pursuant to the OECD/G20 Common Reporting Standard (CRS) to launch exchanges in
See MoreNetherlands: Bill on country-by-country reporting gazetted
The lower house of the Dutch parliament adopted a bill implementing EU directive 2016/881, mandating the automatic exchange of country-by-country reporting information among EU member states on 26th April 2017. On 2nd June 2017, EU directive
See MorePakistan: FBR proposes to introduce a Directorate General of Transfer pricing
Federal Board of Revenue (FBR) has proposed through Finance Bill 2017 to establish Directorate General of Transfer Pricing which shall consist of a Director General and as many Directors, Additional Directors, Deputy Directors, Assistant Directors
See MoreRomania: Country-by-Country reporting requirement modified
The Romanian Ministry of Finance published a draft law on 24 May 2017 to modify the CbC reporting legislation of the country. According to the draft law, all Romanian tax resident entities which are ultimate parent of an MNE Group with annual
See MoreSouth Africa and U.S. sign an agreement on the exchange of country-by-country reports
The competent authorities of South Africa and the U.S. have concluded an arrangement on the exchange of Country-by-Country Reports. On June 5, 2017 the South African Revenue Service (SARS) released the text of the arrangement. According to SARS the
See MoreTurkey: Council of Minister proposes transfer pricing provisions
A draft Communique regarding transfer pricing has been published in Turkey. It generally represents measures of the OECD’s base erosion and profit shifting (BEPS) Action 13 on country-by-country reporting and transfer pricing documentation. The
See MoreTransfer Pricing Brief: May 2017
Italy: Requirement-Rule: According to Decree No.50 published on 24 April 2017, the definition of normal value with the concept of arm’s length will be modified to be more aligned with Organisation for Economic Co-operation and Development
See MoreLithuania: Parliament approves CbC reporting requirements
The Lithuanian Parliament on 23 May 2017, passed amendments to the Tax Administration Law to implement the CbC reporting requirements that will take effect from 5 June 2017. According to law, all Lithuanian tax resident entities that are part of an
See MoreMalaysia: IRBM issues amended tax audit framework for 2017
The Inland Revenue Board of Malaysia (IRBM) issued an amended tax audit framework on 1 May 2017. The aim the amended framework is to ensure that tax audits are carried out in a fair, transparent and impartial manner. The framework outlines the
See MoreUkraine: SFS clarifies the definition of related parties for the recognition of controlled transactions
On 16 May 2017, the State Fiscal Service of Ukraine published a letter No. 9012/6/99-99-15-02-02-15 concerning the definition of related parties for the recognition of transactions controlled and guided by article 52 of the Tax Code of Ukraine. The
See MoreBrazil: Additional guidance on CbC reporting rules issued
Normative Ruling 1,709/2017 of 25 May 2017 amended the 2016 normative ruling that introduced the country-by-country (CbC) reporting obligation in Brazil effective from fiscal year(FY) 2016. According to the new ruling for FY 2016, the Brazilian tax
See MoreIsrael: Status updates of automatic exchange of country-by-country (CbC) reports
The Israel Tax Authority declared the signing of a multilateral agreement for the automatic exchange of country-by-country (CbC) reports and of common reporting standard (CRS) information. The Director of tax authority signed the Multilateral
See MoreIceland issues revised bill for the CbCR
Regulation no. 1166/2016 on the documentation for CbCR (Country-by-Country Reporting) has been further revised by regulation no. 245/2017 on 24 March 2017. The revised regulation is effective on or after 24 March 2017. The revision incorporates two
See MoreHungary: CbC reporting requirements adopted
Hungary released a draft law on country-by-country (CbC) reporting on 10 March 2017 which became effective 15 May 2017. As a result, Hungary fulfilled the harmonisation requirement set by Council Directive (EU) 2016/88) and implemented the
See MoreSlovenia: Proposal for more specific requirements for CbC reporting
The Slovenian Ministry of Finance on 19 April 2017 issued a proposal to amend the rules for the application of the Tax Procedures Act. The proposal provides more specific requirements for CbC reporting. In addition the proposal would introduce CbC
See MoreIndia: Latest update on country-by-country reporting
India has recently included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The first round of CbC reports, if applicable, must be submitted to the
See More